Subject: File No. S7-14-08
From: Douglas McCallum

October 20, 2008

How can anyone pretend that annuity returns linked to stock index returns aren't a "security?" Cloaking variable annuities as non-securities with specious rational is just a flim-flam to generate fees and commissions for un-licensed and possibly less-knowledgeable sales people (less knowledgeable than those who have taken the time to pass the requisite tests to qualify for licensed securities sales).
Access to quick and easy commissions is driving this initiative just as quick and easy commissions fueled the sub-prime mortgage system as a coterie of agents, brokers, appraisers, and investment bankers found a way to sell homes to people who couldn't afford them.
Perhaps the recent collapse in index valuations will drive the unlicensed people out of the bogus indexed annuity business.